Hello!

We are in the process of moving paper documents within customer files to digital and there is the question of whether or not we need to keep the paper documents once they've been scanned digitally. Does anyone have any experience or best practices with regards to this? Thanks!

Knowing what type of documents would be key here. Personally, we shred everything except original signature cards once everything is scanned in.

Primarily we are looking at CIP documents, but also various account maintenance forms as well. Our current deposit origination platform is digital, signature cards are signed and stored electronically, removing the need for a printed document with a wet signature.

Any requirements for physical documents would be a matter of state law. BSA record retention merely says that required records must be "retrievable." Whether you store then via physical copy, microfilm, microfiche, computer magnetic tape, or digital image is up to you.

I don't ever recall anything specifically about needing physical copies of any particular documents for BSA purposes. Someone can correct me if I'm wrong on that.

Two things are in play here. Brian nailed the first in what the record retention rule requires. The second is what your Board approved AML Policy requires.

State statutory laws may not spell it out clearly, but case law is what really matters. Ask the bank's attorney what bank records (if any) MUST be in paper form in order for the bank to prevail in any litigation with customers.